Comment on CFPB-2013-0005-0001

I'm totally supportive of the proposed rule to implement Federal oversight of nonbank student loan servicers. It's abundantly clear to me that some servicers are consistently and intentionally employing plausible deniability strategies where they fail to correct their own errors, and then charge fees for allegedly late or missing payments. Students are held hostage to these predatory practices since there is no way to out except to pay what they don't owe. I've come to realize that It's not incompetence - it's blackmail and completely self-serving. I'm speaking from my personal experience with a small grad school loan. And I'm also a former Associate Director of Financial Aid, former employee of NASFAA, and former employee of the College Board. I'm horrified at what students must be going through, when I am having this much trouble myself. I literally have had no other choice than to go to the Ombudsman for assistance, which is ridiculous given my experience, but there is simply no one at that big non-bank who is willing or empowered to fix anything. I hope that one of your oversight activities might be to specifically require the servicers to have and publicize contact information for an actual human dedicated account manager whom students can call when an issue needs to be escalated. In my case I was only able to get a customer service rep to relay information back and forth to a manager - I was not allowed to speak to her directly. And, the customer service rep was not allowed to give her her name, only her employee number. This treatment of students is completely unacceptable. In regards to cost/benefit analysis, I believe this proposal is a huge cost saving and will be extremely beneficial to the economy. In the case of private loans, they are selling bonds based on securitized student loans -they are only interested in demonstrating a continuous cash flow stream and not what it means for the consumer. I applaud you CFPB! Rock on.